6 Radioactive waste management and decommissioning
6.3 Overview of Ukrainian Legislation on Radioactive Waste Management
casks, as well as for preserved legacy RW storage facilities, which were operated during the previous period and were closed as “disposal facilities”. Based on the safety reassessment results, the period will be determined during which the safety level could be considered reasonable and a decision can be made on the framework for radioactive waste retrieval.
RW retrieval from storage facilities is currently planned from Kyiv SISP storage facilities No. 5, 6, and 7. SNRIU approved the retrieval project. The design decisions were made for radioactive waste sorting and placing into protective casks to ensure further safe storage of retrieved radioactive waste before its sending for processing and disposal at Vektor facilities.
Since 2013, a new module-type storage facility has been operated at Dnipropetrovsk SISP for storage of radioactive waste and disused sealed radioactive sources, which was built due to the investments within technical cooperation with the USA. A large number of radiation sources has been retrieved and transferred to this SISP from bankrupt enterprises remaining since Soviet times under the projects related to decommissioning of irradiation facilities and safe storage of disused sealed radioactive sources supported by BMU/GRS (Germany), and improvement of disused sealed radioactive sources security in Ukraine supported by the United States. In 2013, experimental activities were started at the Kharkov SISP to implement the decontamination technology for tubing contaminated by naturally occurring radionuclides.
In 2014, a mobile system of equipment for safe discharge of disused gamma-radiation sources from biological shielding units was completed and prepared for operation (with support within
cooperation with the Atomic Energy Commissariat of France). Operation of the system is expected at SISP sites in order to discharge disused sealed radioactive sources and place them into protective casks. This will minimize the scope of such radioactive waste, improve safety of its storage, and enhance efficiency of transport for storage in CLTSF.
In 2000, the Law of Ukraine (No. 1688-III of 20 April 2000) ratified the “Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management”
confirming the need for compliance with the safety objectives and fundamental safety principles during RW management.
At the same time, the valid documents of Ukraine include the documents that were developed many years ago and should be revised and harmonized with the new requirements and standards of the IAEA and the EU, as well as accounting for wider developments within the Ukrainian regulatory framework. This problem will be partially solved after enforcement of two new regulatory documents, being developed in the framework of the Project “WASTE”, supported by the NRPA. These documents will establish general safety requirements for predisposal radioactive waste management and for disposal of radioactive waste, harmonized with IAEA standards and WENRA reference levels.
Proposals for further development:
1) In accordance with current regulations, RW can be divided into groups (according to exemption levels for a group of radionuclides contained in RW), categories (according to specific activity), classes (according to type of generated RW) and types (according to acceptable type of disposal).
Direct correspondence between groups, categories, classes and types of radioactive waste is not defined. There is no clear and unambiguous succession of radioactive waste sorting criteria by producers and waste separation criteria according to type of acceptable disposal. Specifics of classification and disposal of Chernobyl-origin RW are not shown either. The use of existing classifications and in situ sorting of radwaste by groups and categories ensure personnel safety in RW management but do not take into account acceptable disposal types. In many cases, this necessitates repeated sorting of waste prior to conditioning in order to meet safety requirements for disposal.
Taking into account new IAEA standard GSG-1 “Classification of Radioactive Waste” [71], international experience and recommendations of IRRS-2008 and IRRS-2010 missions, Ukraine initiated the revision and improvement of radioactive waste classification. The objective is to implement the radioactive waste classification system that would reflect the method of RW final disposal. In the framework of EC INSC, project U4.01/08-C "Improvement of the RW Classification System in Ukraine" was implemented during 2010-2012. Implementation of the recommendations obtained under this project into the national regulatory and legal system is in progress.
It is necessary to establish regulatory requirements for radioactive waste classification for disposal purposes considering modern approaches to the optimization of disposal systems and considering the specifics of disposal in the Chernobyl exclusion zone. The numerical limits for RW classes will be thus determined on the basis of safety assessment in accordance with disposal concepts.
The introduction of new classification for disposal purposes is intended to optimize radwaste management and does not exclude the application of existing classifications that properly address safety issues at individual stages of RW management (for more detail, see Section 8.4, issue 8.4.1).
2) The Ukrainian legal and regulatory framework does not establish regulatory requirements for
“current exposure situation” and “remediation”. In particular, the reference levels of doses for the public under current exposure situations are not defined, although this is necessary for regulating the safety of legacy storage/disposal facilities and sites in the exclusion zone and at ‘Radon’
enterprises. Thus, it is planned to develop regulatory requirements for “current exposure situation”
and “remediation” as applied to legacy storage/disposal facilities and sites in compliance with the new International Basic Safety Standards (for more detail, see Section 8.4, issue 8.4.2).
3) The Ukrainian legislation contains mainly the general requirements for emergency preparedness.
For nuclear facilities, detailed requirements are established on some issues. Requirements for emergency preparedness for radioactive waste management facilities have their specifics;
therefore, it is necessary to establish appropriate regulatory requirements (for more detail, see Section 8.4, issue 8.4.3).
6.3.2 Requirements for safety assessment
According to the Law of Ukraine “On Authorizing Activity in Nuclear Energy [10], RW is managed based on licenses, individual permits and certificates. Basic principles of the authorizing activity during RW management are established in Article 5 of this Law; they specify the need for comprehensive safety assessment in making decisions on issuance or refusal to issue the authorizing documents.
It is required that the operator should develop safety justification to be submitted to the SNRIU for licensing of facilities or activities for RW predisposal and disposal management. The SNRIU
conducts review and independent assessment of the operator’s justifications and makes a regulatory decision.
The requirements for the structure and contents of SARs are established in the following documents:
• Requirements for the Structure and Contents of the SAR for Near-Surface Disposal Facilities for Radioactive Waste (ND 306.3.02/3.038-2000) [72];
• Requirements for the Structure and Contents of the SAR for Radioactive Waste Treatment Facilities (ND 306.3.02/3.043-2001[73];
• Requirements for the Structure and Contents of the SAR for Radioactive Waste Storage Facilities (ND 306.4.142-2008) [74].
However, these documents do not contain detailed requirements for safety assessment
methodology and safety justification of relevant facilities; some aspects of these regulations are outdated.
SNRIU is supported by the EC within the International Cooperation Program on Nuclear Safety (TACIS and INSC) to assist the SNRIU and its TSO in developing their capabilities and application of Western European experience related to safety principles and best practices of RW management.
In particular, Project INSC UK/TS/39 “SNRIU Support in Licensing of Radioactive Waste Management Facilities” was implemented during 2009-2013.
Two guidelines were developed in the framework of Project UK/TS/39 with participation of international experts:
• Guideline for common impact of the Vektor site with multiple facilities for radioactive waste processing, storage, and disposal (subtask 1a, revision 3, March 2013);
• Guideline for safety reassessment of the existing storage/disposal facilities and decision-making criteria concerning subsequent measures at these facilities (subtask 1b, revision 3, March 2013).
The guideline for safety assessment of temporary confinement points for radioactive waste in the Chernobyl exclusion zone was developed in the framework of new Project EC INSC UK/TS/46
"SNRIU Support in Safety Regulation of Radioactive Waste Management and Harmonization of Regulatory Requirements on Nuclear and Radiation Safety".
In addition, the development of “Guideline on Radioactive Waste Characterization, Accounting and Monitoring” is currently under development in the framework of Project EC INSC UK/TS/46
(Subtask 2.1).
Proposals for further development:
1) Regulatory requirements for safety assessment methodology should be developed based on IAEA Safety Standard GSR Part 4 “Safety Assessment of Facilities and Activity. General Safety Requirements”, as well as lower-level documents establishing specific requirements for safety substantiation and assessment at different stages of RW management (for more detail, see Section 8.4, issue 8.4.4).
2) Since the Radioactive Waste Management Strategy in Ukraine envisages the development of a disposal facility for high-level and long-lived radioactive waste in deep geological formations, requirements for the structure and contents of the SAR for a geological repository should also be developed (for more detail, see Section 8.4, issue 8.4.4).
6.3.3 Safety culture and management system for the operator
Measures are taken to improve the radioactive waste management system including the development of the national RW management operator at the stage of long-term storage and disposal, namely the Centralized Enterprise for Radioactive Waste Management (CERM) to ensure conditions for efficient implementation of the state policy in the field of radioactive waste
management.
At present, there are two regulatory documents with general requirements for the management system (quality system):
• General requirements for the quality system in nuclear energy use;
• Requirements for the quality system of the nuclear facility operator.
These documents pay special attention to safety culture formation, individual responsibility and duties of the operating organizations (operators).
Proposals for further development:
1) It is necessary to develop specific regulatory requirements for the operator’s quality system at the stage of disposal, including requirements for safety culture during RW management (for more detail, see Section 8.4, issue 8.4.5).
2) Regulatory requirements for the operator’s quality system for radioactive waste management before disposal should be developed based on the same approach for the licensee that undertakes radioactive waste storage and processing (for more detail, see Section 8.4, issue 8.4.5).
6.3.4 Conclusions
The analysis has revealed the following significant regulatory threats in the area of radioactive waste management.
1) There are no comprehensive regulatory requirements to ensuring the safety of RW management that would take into account the consistency of individual RW management stages up to final disposal. There are no clear and unambiguous criteria for RW sorting in situ that would take into account waste classes in accordance with acceptable disposal concept and specific requirements and rules for RW management stages. The national radioactive waste management strategy
2) An effective classification system for radioactive waste is not in place.
3) There are no requirements for remediation of temporary RW confinement sites in the exclusion zone and legacy waste disposals at ‘Radon’ sites that would comply with modern approaches to regulation of existing exposure situations.
4) There are no specific requirements for safety culture and management of RW-related activities.
5) There are no systemized requirements on safety assessment and justification of RW management facilities.
6) There are no requirements for the structure and contents of the Safety Analysis Report SAR on Geological Disposal facility.
7) There are no specific requirements for the design, implementation and follow-up of the institutional control needed for disposal facilities.
8) There are no specific requirements on emergency preparedness for RW management facilities.
Also the operator should further improve the operational procedures for three existing near-surface disposal facilities for short-lived waste at the Vektor site.
Comprehensive regulatory requirements should be applied to mitigate the identified threats – a two-level system of regulations shall be developed. The existing regulations were developed at different times, govern separate RW management aspects and are not harmonized.
High-level regulations on safety provision during predisposal and for disposal are currently under development with NRPA support under on-going project М17-14/21.
These regulatory documents are intended to mitigate threats 1), 2), 3), and 4) regarding general safety provisions.
The general provisions of these documents shall be detailed/specified in lower-level regulations.
The following structure of lower-level documents may be proposed as an option.
The following structure of lower-level documents is under consideration.
General Safety Provisions for Predisposal Radioactive Waste Management
Working title of regulation Relation to existing
regulations Mitigation of threat Requirements and rules for preliminary
treatment of radioactive waste prior to processing and conditioning
To replace SPAS-88,
SPORO-85 1) ; 8)
Requirements and rules for radwaste processing and conditioning to the state acceptable for storage and/or disposal
New 1); 8)
Requirements and rules for long-term storage
of radioactive waste Revision of ND
306.4.143-2008 1); 8)
Requirements for the management system
for predisposal radwaste management New 4)
Requirements for safety assessment methodology and safety justification for radwaste treatment facilities
New 5)
Requirements for the structure and contents
of SAR for radwaste treatment facilities New to replace NP 306.3.02/3.043 -2001, planned under АР-2012
5)
Requirements for safety assessment methodology and safety justification for radwaste storage facilities
New 5)
Requirements for the structure and contents
of SAR for radwaste storage facilities Revision of NP 306.4.142
-2008 5)
General Safety Provisions for Disposal of Radioactive Waste
Working title of regulation Relation to existing
regulations Mitigation of threat Requirements for site selection for RW
disposal facilities
Revision of NP 306.4.149-2008
1)
Requirements and rules for RW disposal in
surface and near-surface facilities New, to replace ND
306.604.95 1); 2); 7); 8);
General provisions for RW disposal in
geological repositories Revision of ND
306.4.133-2007 1); 2); 7); 8);
Requirements for the management system
for RW disposal New 4)
Requirements for safety assessment methodology and safety justification for surface and near-surface RW disposal facilities
New 5)
Requirements for the structure and contents of SAR for surface and near-surface RW disposal facilities
New, to replace NP 306.3.02/3.038-2000, planned under АР-2012
5)
Requirements for safety assessment methodology and safety justification for geological RW repositories
New 5); 6)
Requirements for the structure and contents New 6)
The lack of regulatory documentation with systemized requirements for consistent stages of RW management up to final disposal, including those on the management system and quality system for RW-related activities, causes risks of applying a non-optimized waste management system.
There are risks of waste accumulation without appropriate characterization and sorting as well as late transfer for further treatment. The main principle of RW minimization is not adequately implemented. Waste management does not fully take into account the goal of this activity – final disposal.
The existing regulatory requirements on RW disposal, in particular existing waste classification for disposal purposes, cause risks of using non-optimized disposal facility designs and do not allow for the specifics of RW disposal in the Chernobyl exclusion zone.